Privacy & Cookie Policy

PRIVACY POLICY

This document explains why the data controller, Queen of Clubs Lifestyle Luxury Services Ltd, with registered office at 3 Water House Square, 138 Holborn EC1N 2SW, London, UK, Company Registration no. 06949341, VAT 975393178, email address privacy@qofclubs.com, dpo@qofclubs.com (hereinafter, "Data Controller" or “Company”), processes the personal data of the users who access the website www.queenofclubs.com (hereinafter, "Website"), interact with it and enquire for the various services offered therein.

Purposes and Legal Basis

The Data Controller processes the users’ personal data:

  1. to allow them to register on and log in to the Website, create an account, get in touch with the Company and enquire about the services offered by the Company. The legal basis is the proper management of the user's request;
  2. for purposes related to the defence in legal proceedings, management of complaints and litigation, possible recovery of credits, prevention of fraud, including computer fraud and/or illegal activities put into effect to the detriment of the Data Controller and/or to the Website. The legal basis is the legitimate interest of the Data Controller and/or of third parties which, according to the Data Controller's evaluations, does not prevail over the rights and fundamental freedoms of the user;
  3. for purposes related to the execution of legal obligations, regulations, national and/or international laws applicable to the Company. The legal basis is the fulfilment of legal obligations;
  4. based on the express and specific consent of the user, to send via e-mail communications of a commercial and/or promotional nature and/or informative newsletters concerning the services and experiences offered by the Company. The legal basis is the user's consent, which the user may freely provide to the Data Controller.

The need to provide personal data

The provision of personal data for the purposes referred to in points a), b) and c) above is necessary. Indeed, failure to provide the data makes it impossible to register on the website, create a personal account, and enquire about the services offered by the Company.

The provision of personal data for the purpose referred to in point d) above is not necessary. The failure to provide the data for this purpose makes it impossible for the user to receive promotional communications but does not in any way prevent the user from registering on the Website and using the related services.

Communication of personal data

The personal data provided by the user will not be disclosed and may be communicated by the Data Controller only for the purposes described in this document, to the categories of data recipients indicated below:

  • companies, collaborators, consultants and/or freelance professionals that the Data Controller may rely on for the performance of technical or organizational tasks related to the Website or operators cooperating with the Data Controller to correctly provide and operate its services;
  • persons, companies, or professional firms that help and advise the Data Controller, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters;
  • companies used by the Data Controller to carry out marketing activities in relation to the services that the Data Controller promotes on the Website;
  • companies belonging to the same corporate group of the Data Controller, including subsidiaries and/or associated companies as provided under the law, also located outside the UK or European Economic Area (EEA), to carry out internal reporting activities and/or for the shared management of the customer’s database;
  • persons who have the right to access the data in accordance with law or directives issued by the authorities.

The persons/entities belonging to the above-mentioned categories will use the data as autonomous data controllers or data processors, as correctly appointed by the Data Controller. The data will also be processed by those who belong to the Data Controller's organization (employees, collaborators, etc.) in their capacity as natural persons acting under the authority of the Data Controller.

These persons/entities may be in countries not belonging to the United Kingdom or the European Economic Area (EEA). In this case, the Data Controller adopts the measures provided for by the UK GDPR to legitimize the transfer of personal data outside the UK; such measures include the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, approved by the UK Government and the Information Commissioner's Office (ICO). The list of persons to whom the data is or may be communicated can be requested by sending an e-mail to privacy@qofclubs.com.

How long my personal data is processed and stored

The data provided by the user when registering with the Website will be kept until the user remains registered with the Website; subsequently, such data will be kept for 6 years following the user's cancellation from the Website.

With specific reference to marketing purposes, the Data Controller will keep the users’ data until the user opts out and, in any case, for a maximum of 2 years from the collection.

Privacy rights

The user may exercise, in cases expressly regulated by law, the rights provided for in Article 15 et seq. of the UK General Data Protection Regulation (UK GDPR). The user, in particular, has the right to:

  1. ask for confirmation that his/her personal data is being processed and request the access to information relating to the processing;
  2. request the correction of inaccurate or incomplete data;
  3. request the deletion of data;
  4. request the limitation of the processing;
  5. request to receive, in a structured, commonly used and machine-readable format, the personal data concerning the user and to send them to another data controller or request the direct transmission from one data controller to another, if technically feasible (so-called “data portability”);
  6. revoke at any time the consent formerly provided, without prejudice to the lawfulness of the processing based on the consent before the withdrawal;
  7. completely or partly object, on legitimate grounds, to the processing of personal data.

These rights can be exercised directly by sending a communication to the following e-mail address: privacy@qofclubs.com.

Finally, the user has the right to lodge a complaint with the Information Commissioner's Office (ICO) in the UK (www.ico.org.uk) or, if applicable, with the national Data Protection Authority of the country where they reside, work, or where the alleged infringement took place if he/she believes that the processing of the data violates/violated the legislation on the protection of personal data.

COOKIE POLICY

During navigation and interaction with the Website, the Data Controller will collect, through cookies and similar technologies, certain personal data such as, for example, the pages viewed, the links or buttons clicked, the date and time of access, and the IP address (so-called "navigation data").

What is a cookie and what is it used for

Cookies are generally text strings that the websites visited by the user or different websites or web servers place and store - directly or indirectly - within a terminal device available to the user. The information encoded in cookies may include personal data, such as an IP address, a username, a unique identifier, or an email address, but it may also contain non-personal data, such as language settings or information on the type of device a person is using to browse the Website.

Classification

Cookies and, to a large extent, other tracking tools can have different characteristics from a temporal perspective and thus be considered based on their duration (session or permanent) or from a subjective point of view (depending on whether the publisher acts independently or on behalf of a "third party").

The classification that responds to the rationale of the law and therefore also to the need to protect the individual is ultimately based on two macro-categories:

  • Technical cookies: used for the sole purpose of making navigation and use of the web faster and easier for the user, as they, for example, simplify certain procedures when making an online purchase, when logging into restricted areas, or when a website automatically recognizes the language usually used. A particular type of technical cookies is the so-called "analytics cookies," used to collect information, in aggregate form, on the number of users of a site and how they visit the site itself, and thus to process general statistics on the service and its use.
  • Marketing and Profiling cookies: used to link specific actions or recurring behavioural patterns in the use of the offered functionalities (patterns) to specific, identified, or identifiable subjects, to group the different profiles within homogeneous clusters of different sizes, so that it is possible for the controller, among other things, to modulate the provision of the service in an increasingly personalized way beyond what is strictly necessary for the provision of the service, as well as to send targeted advertising messages, i.e., in line with the preferences expressed by the user while surfing the web.

What cookies are installed on the Website?

Technical Cookies: these cookies help make the Website usable by enabling basic functions such as page navigation and access to secure areas. The Website cannot function properly without these cookies; therefore, their use does not require the user's consent. The legal basis for the processing regarding the use of these cookies is the legitimate interest of the Data Controller to allow users to properly navigate the Website and ensure its security.

Statistics: these cookies help us process aggregate statistics to understand how users interact with the Website, to evaluate the effectiveness of the services offered on the Website, and to measure its traffic and experience. The legal basis for the processing regarding the use of such cookies is the consent that the user can freely choose to provide to the Company via the banner or by accessing the specific cookie section.

Marketing: these cookies are used to track visitors across the Website. The purpose is to display advertisements that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers. The legal basis for the processing regarding the use of such cookies is the consent that the user can freely choose to provide to the Company via the banner or by accessing the specific cookie section.

Other: Third parties may also collect information from our Website via cookies, third-party plug-ins, and widgets (e.g., Instagram, Facebook, etc.). In these circumstances, the third parties collect data directly from your web browser, and the processing and handling of such data are subject to their respective privacy policies.

How to disable cookies?

In addition to being able to choose whether to accept or reject all or part of the cookies used by the Website through the mechanisms illustrated in this Cookie Policy, the user can also delete the Website's cookies from their browser through the browser's own settings.

However, disabling the use of all cookies will compromise some of its functionalities.

This Privacy & Cookie Policy may be modified by the Data Controller at any time, through the publication of a new version on the Website. Your continued use of the Website will constitute your unconditional acceptance of any modifications and revisions to the Privacy & Cookie Policy. We therefore invite you to check for updates regularly.

Last update – July 2026 (V1)

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